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The key to the scheme was the written attack (the "Article" ) on Nobilis' business which the defendants prepared and anonymously posted under the pseudonym "The Emperor Has No Clothes" to the website "Seeking Alpha" (www.seekingalpha.com) ("Seeking Alpha" ). The Article made numerous statements of purported "fact" about Nobilis' business that were false and defamatory, including allegations that the Company's auditors resigned amid controversy (untrue), CFOs had been shuffled to hide impropriety (untrue), insiders had sold all of their Nobilis Common Stock (untrue), that the Company was hiding poor performance behind acquisitions (untrue), that major insurers would not pay for certain medical procedures billed by Nobilis (untrue), and several other false, defamatory and misleading statements.

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